This information is intended to give guidance on satisfying the minimum requirements for labelling products according to the Soil Associations standards for health & beauty products (revision 16 2009). This guide does not conflict with or attempt to replace the EU Cosmetics Directive 76/768/EEC1 (hereafter referred to as ‘the directive), national weights and measures guidelines, or other statutory, national, and international requirements for cosmetics products. The ‘statutory requirements’ section is an interpretation of the requirements for the EU market at the time of writing. All licensees are advised to contact their local trading standards office if they are unsure how to apply the requirements to their products.
All labels must gain written approval from Soil Association Certification Ltd (SACL) before final printing, and the product must be included on your Soil Association trading schedule (accompanied by a valid certificate) prior to launch. If labels are printed without approval and are found not to be compliant, withdrawal of the non-compliant labels may be requested.
The product specification must be approved prior to label approval. Where this is not possible, the label can only be given provisional approval.
Please send in draft copies of your labels to us for approval before you print them.
We will review your labels within five working days and inform you of any changes that you need to make.
Once any changes have been made and sent to us, we will send you written approval for your labels.
Please remember that, if you make any changes to a multi-ingredient product specification, you will need to amend the ingredients section on the label accordingly, and send the revised label to us for approval.
Note: generic label designs can be submitted for ranges of single-ingredient products, if the basic design is the same for all products.
If labels are printed without our approval, and they do not comply with the labelling standards, we may ask for them to be reprinted.
General labelling requirements for all SA organic products
Use of the Soil Association symbol - The Soil Association organic symbol is a registered certification mark (®) of Soil Association Limited. You must not use the symbol or refer to the Soil Association without prior approval from SACL.
The Soil Association symbol – Products certified by SA Certification to Soil Association standards, are able to benefit from the using the widely recognised Soil Association symbol. From July 2010, it is compulsory to display the current version of the symbol on all final product packaging. You can use the Soil Association symbol on other literature such as company stationary or your web site, as long as you make it clear whether the symbol relates to all your products, or a specific product range only. When using the symbol, the minimum size is 10mm diameter, (unless space is restricted, for example on a sugar sachet), no changes must be made to the symbol such as rotating part of the symbol, or adding an outer ring, and it must appear entirely in either black or white. The symbol can be used over backgrounds such as a photograph as long as it remains clear and legible. Please refer to Soil Association standards for full details of use of our symbol.
The labelling must be accurate – Your labels must clearly and accurately describe the product and your sales description and product name must accurately describe the product. For example if you label your product as ‘organic mint foot balm’, it must contain organic mint. If your product does not contain organic mint, you can only label it as ‘organic foot balm with mint’
100% claims - If you want to label your product as ‘pure’ or ‘100% organic’, you can only do so if all the ingredients are organic. If you add water, salt or any other non-agricultural ingredients, you may not label it as ‘100% organic’.
Organic claims - You may label your product as ‘organic’ only if more than 95% of the ingredients are organically produced. For products where at least 70% of the ingredients are organic but less than 95% of the ingredients are organic, your label must show the percentage of organic ingredients within the product title. We interpret ‘in the product title’ to be within or right under the product name and in the same (or similar) size and style when the word 'organic' is in the brand name, or in the same visual field as the product name (180º) and in the same (or similar) size and style when the word 'organic' is not in the brand name.
If you make a claim on your label then you must be able to substantiate it.
You must not use phrases such as ‘GMO-free’ unless you can prove this, if challenged.
Note: we suggest you use ‘organic standards prohibit the use of GM materials’, or ‘non-GM’.
You must not use phrases such as ‘pesticide free’ unless you can prove this, if challenged.
Note: we suggest you use: ‘organic agriculture aims to avoid the use of artificial pesticides and fertilisers’ ‘organic standards restrict the use of artificial pesticides and fertilisers’, or ‘grown under organic standards which minimise the use of artificial pesticides and fertilisers’.
We do not endorse any particular product. You must not use phrases such as ‘endorsed by the Soil Association’ on labeling or other advertising material.
Statutory requirements
Due to our policy of best practice, we insist that all labels comply with the relevant legislation where we have knowledge of that legislation. Whilst not necessarily within our remit, we may refuse to accept a label where we believe it does not carry all of the information required by law. However, this does not mean that we check that your label complies with all relevant legislation. Our advice is that you check with your local trading standard office to ensure your product is accurately labelled according to the law before going to print.
Containers and/or packaging must bear, in indelible, easily legible and visible characters:
- the name or trade name and address or regitered office of the manufacturer or of the person responsible for marketing the cosmetic product within the EU
- the nominal contents at the time of packaging, by weight or by volume
- for products with a minimum durability of less than 30 months: the date of minimum durability indicated by ‘Best used before the end of ...’
- for products with a minimum durability of more than 30 months, the period of time after opening for which the product can be used without any harm to the consumer (this information is indicated by a special symbol representing an open cream jar)
- particular precautions for use
the batch number or product reference to permit identification
- the product function.
Labeling of ingredients – statutory requirements
The label must contain a list of ingredients, preceded by the word ‘ingredients’, in descending order of weight to 1%, and in whichever order you prefer thereafter. Perfume and aromatic compositions must be referred to only by the word ‘perfume’ or ‘aroma’, except where these have been identified as a significant cause of allergic reactions in sensitive consumers. For a comprehensive description of INCI (International Nomenclature of Cosmetic Ingredients) names which should be used to describe an ingredient, please refer to the COSING website: http://ec.europa.eu/enterprise/sectors/cosmetics/cosing/index_en.htm
Labeling ingredients - Soil Association requirements
Your labels must identify the organic and non-organic ingredients in the ingredient panel.
You may list ingredients as ‘organic’ only when the whole of that ingredient is of organic origin. You may indicate this by using an asterisk or similar mark following the name of the ingredient which then refers to a statement elsewhere on the label. For organic ingredients transformed by a chemical process, you must as ‘made with organic ingredient’ or similar.
For single-ingredient products (essential oils sold individually), your labels must show the country of origin. If there is more than one country of origin the term ‘imported’ or ‘produce of more than one country’ may be used.
1. Link to the Cosmetics Directive 76/768/EEC www.ec.europa.eu/enterprise/sectors/cosmetics/documents/directive/index_en.htm
Soil Association Certification Limited, South Plaza, Marlborough Street, Bristol BS1 3NX
T 0117 914 2411 F 0117 314 5046 E proc.cert@soilassociation.org W www.soilassociation.org/certification
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